FAA STCs on Canadian Registered Aircraft

[Armstrong]

Hi, I’ve got a Piper PA-22/20 that I bought a few (FAA) STCs for; lightweight battery, Stewart wing tips, and EZ flap handle. Aside from my AME following the installation instructions and having the information for continued airworthiness, is there anything beyond log book entries and signed/stamped STC from the STC holder required?

Thanks in advance,

John

[PilotDAR]

The PA-2/20 is listed on the "U.S. Eligible Aircraft List"

https://tc.canada.ca/en/aviation/aircra ... #wb-auto-4

As such, TC accepts FAA issued STC's for these aircraft ('same state of design), so a Canadian, or "familiarized STC" is not required, unless the STC is from EASA, then it could be. Of course a Canadian STC is acceptable. Were the airplane be of a model/type not on that list, a Canadian, or familiarized FAA STC would be required. The Cessna 206 is an example, where all the older 206's are on that list, so FAA STC is accepted, but the C206H does have a Transport Canada type certificate, so any STC's for the 206H would have to be familiarized by TC.

So for your plane, FAA STC's are okay. I believe that your AME has to submit a "045" mod report, but that's just administrative. You are responsible for maintaining an inspection checklist for your plane, which now should also reference any ICA's which came with any of those mods. You are responsible for presenting the inspection checklist and all ICA's to your AME/AMO

Though probably not a factor for your plane with those mods, there is also a maintainer responsibility to assess the inter-relationship of the mods to each other, and to any other mods already on the plane. This is generally benign, but is a required task, for which the AME could later be held responsible if not done and documented. The problem is that most AMEs/AMOs, though great at maintenance, are not familiar with assessing the inter relationship of mods, and things get missed. The TBS has commented on this in a few recent reports. But, as I said, for those mods on your plane, very unlikely a factor - no problem.

[Armstrong]

Wow! Thanks for the quick and clear response! Much appreciated.

[photofly]

So for your plane, FAA STC's are okay. I believe that your AME has to submit a "045" mod report, but that's just administrative.

I believe you're thinking of a report under CAR 571.12/Appendix L. (https://tc.canada.ca/sites/default/file ... repair.pdf) Anyone can submit it - you or your AME - just as long as someone does.

[Armstrong]

Thanks! Looks like the 0045 form is out-moded?

When I look at the TC criteria for the major mod I interpret the battery and flap handle extension to be minor mods (no report required) and because the Stewart tips will decrease stall speed a little they are considered a major mod and require the report?

[groncher]

Since they are all STC's I would report them all. Can't hurt. You can put them all on the same report.

STCs are considered "approved data", which is one of the criteria for a major mod.

STD 571 appendix L gives a sample form.

[Armstrong]

Excellent, thanks all for the help. Looks like I’ve come to the right place!

I’m also hoping to put a Sutton exhaust on my PA-22/20. The Sutton is STC’d for the Pa-18, but not the PA-22 or 20. Lots of them on in the US via 337s or field approvals. Is the DAR here in Canada the only approach, or is there an even simpler way?

The Sutton does not increase power, but can eliminate the antiquated original system with the troublesome AD (messing with exhaust studs every 100 hrs) and would be much safer for the occupants of the A/C.

[PilotDAR]

or is there an even simpler way?

Not in Canada at present. STC, serialized STC, are the only approved data (which is required for a different exhaust). For propeller and exhaust changes, TC is beginning to take a real interest in noise compliance. More so props (which have been a certification misery in recent years), but exhaust changes were also mentioned during the TC delegate's roundtable to other week. Once TC starts really looking hard at this, it won't be worth the effort to install changed exhaust which is not STC'd and accompanied by a noise certificate.

There are European manufacturers of STC'd exhausts which are accompanied by noise certificates, but generally only for common types, and may not necessarily have an STC acceptable in Canada.

Or... Owner maintenance....

[Armstrong]

Well that settles the exhaust question. Thanks to all for the help!

[fish4life]

or is there an even simpler way?

Not in Canada at present. STC, serialized STC, are the only approved data (which is required for a different exhaust). For propeller and exhaust changes, TC is beginning to take a real interest in noise compliance. More so props (which have been a certification misery in recent years), but exhaust changes were also mentioned during the TC delegate's roundtable to other week. Once TC starts really looking hard at this, it won't be worth the effort to install changed exhaust which is not STC'd and accompanied by a noise certificate.

There are European manufacturers of STC'd exhausts which are accompanied by noise certificates, but generally only for common types, and may not necessarily have an STC acceptable in Canada.

Or... Owner maintenance....

If I’m not mistaken owner maintenance doesn’t alleviate the requirement for STC’s or the use of certified parts etc like an experimental aircraft. Doesn’t owner maintenance just allow a non-AME to be the one to do the inspections and maintenance on the aircraft but it still needs to be done to certified standards with certified parts?

[PilotDAR]

Doesn’t owner maintenance just allow a non-AME to be the one to do the inspections and maintenance on the aircraft but it still needs to be done to certified standards with certified parts?

That's a great way to look at it, and in its most pure form, yes. But, OM was built to have some fudge room for lessened standards, which is why it's not internationally recognized. The recently more strict requirements to demonstrate noise compliance are not being applied to OM airplanes with anywhere near the vigor of certified planes. The "conformity" of you OM airplane is more regulated by a TC M&M Inspector, should they choose to be involved. These inspectors often have a very practical perspective on "compliance", where the branch of TC who issue STC's are very by the book. Noise compliance is now prominent in that book.

[photofly]

OM gets a pass on the standard of airworthiness for parts installation under 571.13, and also major modifications only require “acceptable data” rather than “approved
data” or “specified data”. And a release can be signed by the owner. Aren’t those the main differences?

[Hornblower]

The rule requires the person who performed the mod (or repair) to report it ( not even necessarily the person who signed the m/r). Weather it really matters who reports it, who knows. It would depend on what persnickety TC inspector is after you. Not all STCs have to be reported though; only those that constitute a “ major” ( see CAR 101.01). For example the Stewart tips could not be major as they make no noticeable (a negligible) difference - look cooler though. And when doing “majors” on owner maintained, no data at all is required … just saying’.

[photofly]

The rule requires the person who performed the mod (or repair) to report it

I'm curious to know what rule says that. I can only find 571.12:

(1) A major repair or a major modification shall be reported to the Minister by means of a Major Repair or Major Modification Report in accordance with the specifications set out in Appendix L to this standard.

The form in Appendix L includes the details of the person who performed the modification but there's no comment on who has to file the report. Appendix L says "A copy of the report must be completed" - again, not by whom.

What am I missing?

[Hornblower]

You’re not reading the actual rule. Standards are not rules.

[photofly]

Got it:

571.12 A person who performs a major repair or major modification on an aeronautical product or installs on an aircraft a part that has undergone a major repair or major modification shall report the action to the Minister in accordance with the procedures specified in section 571.12 of the Airworthiness Manual.

But who's the person performing the modification? Appendix L requires the report to contain in block 4 "the name and permanent address of the person or organization who accomplished the repair or modification." So we are drawing a distinction between the person who performs the modification and the person who accomplishes the modification. It must therefore be possible that they are different organizations or people.